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Fri 1 Apr 2022 19 52 10 0000 Re Zeeman Discovery 17Fe6B06 2

Field Value
Category Discovery > Written Discovery
Confidence high
Reason [opus] Re: Zeeman Discovery email from opposing counsel
Original File fri_1_apr_2022_19_52_10_0000_re_zeeman_discovery_17fe6b06_2.eml
File Type EML
Source gmail-export
fri_1_apr_2022_19_52_10_0000_re_zeeman_discovery_17fe6b06_2.eml

Email

Header Value
From Lucy Aquino <Lucy.Aquino@swiftcurrie.com>
To "Sally L. Monico" <SCook@mmatllaw.com>
CC Sarah Zeeman <szeeman@gmail.com>, "Eric B. Coleman" <ecoleman@wczlaw.com>, Tania Tuttle <ttuttle@mmatllaw.com>, "Richard J. Capriola" <rcapriola@wczlaw.com>, "Joanie J. Williams" <jwilliams@wczlaw.com>
Subject Re: Zeeman Discovery
Date Fri, 01 Apr 2022 19:52:10 +0000
Email Body
Sally,

I’m reviewing on my phone and can’t redline, but the comments on ROG 2 need to be removed.

Sent from my iPhone


Lucy Aquino
Attorney
Lucy.Aquino@swiftcurrie.com
404.888.6202Office
1355 Peachtree St. NE / Suite 300 / Atlanta, GA 30309
NOTICE:  This email message and all attachments may contain legally privileged and confidential information intended solely for the addressee.  If you are not an intended recipient, your receipt of this email and its attachments is the result of an inadvertent disclosure or unauthorized transmittal.  Sender reserves and asserts all rights to confidentiality, including all privileges that may apply.  Pursuant to those rights and privileges, you are hereby notified that you may not read, copy, distribute or otherwise use this message or its attachments. If you have received this message in error, please notify the sender by email and delete all copies of the message and the attachments immediately.  NO DUTIES ARE INTENDED OR CREATED BY THIS COMMUNICATION.  If you do not have a signed fee contract or engagement letter with this firm, this firm does NOT represent you as your attorney.
nosig
On Apr 1, 2022, at 15:38, Sally L. Monico <SCook@mmatllaw.com> wrote:


All, see attached final drafts of ROGS and RPDS for your review.

Please review the track changes and comments.  Eric and I have discussed objections he will add to RPD responses.

Sarah, I did my best to keep most of your voice/narrative responses but did remove certain portions which were non-responsive to the individual requests.  I also revised to make some of the terms used consistent throughout.

Please review and let me know if we have your approval to finalize and produce to counsel for Sweatman.


Sally Monico
11625 Rainwater Drive | Ste. 125 | Alpharetta, Georgia 30009
Direct:  404.365.4506
Main: 404.266.9171
smonico@mmatllaw.com<mailto:smonico@mmatllaw.com> *PLEASE NOTE MY NEW EMAIL ADDRESS


CONFIDENTIALITY NOTICE
No attorney-client relationship exists by virtue of this communication in absence of an engagement letter or fee contract. In addition, unless you are in the To: or CC: line of this email, you are not an intended recipient. The information accompanying this email transmission may contain confidential or legally privileged information meant for ONLY the intended recipient. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or reliance upon the contents of this email is strictly prohibited. If you receive this email in error, please delete this email and notify the sender immediately.



From: Sarah Zeeman <szeeman@gmail.com>
Sent: Friday, April 1, 2022 3:06 PM
To: Sally L. Monico <SCook@mmatllaw.com>
Cc: Eric B. Coleman <ecoleman@wczlaw.com>; Tania Tuttle <ttuttle@mmatllaw.com>; Lucy Aquino <Lucy.Aquino@swiftcurrie.com>; Richard J. Capriola <rcapriola@wczlaw.com>; Joanie J. Williams <jwilliams@wczlaw.com>
Subject: Re: Zeeman Discovery

Lights  should be july 16
The Sweatmans shined lights into windows of Zeeman’s property on multiple occurrences including, but not limited to December 26, 2020; July 16, 2021[SZ1] ; and September 30, 2021, as
________________________________

 [SZ1]July 16



also - remove - all 3  recordings.

It's only in one or 2 of Linda's recordings
In addition, Sweatman will produce three audio recordings from Linda Abaray at

On Fri, Apr 1, 2022 at 2:37 PM Sarah Zeeman <szeeman@gmail.com<mailto:szeeman@gmail.com>> wrote:
yes -june 25
https://prnt.sc/bWvOa7ejU3Qr<https://prnt.sc/bWvOa7ejU3Qr>
https://www.dropbox.com/s/uibjotxogk4yqem/Sarah%20Zeeman%20Demand%20letter_communication%20Sweatman.pdf?dl=0<https://www.dropbox.com/s/uibjotxogk4yqem/Sarah%20Zeeman%20Demand%20letter_communication%20Sweatman.pdf?dl=0>

On Fri, Apr 1, 2022 at 2:32 PM Sarah Zeeman <szeeman@gmail.com<mailto:szeeman@gmail.com>> wrote:
I'm incorrect again - sorry - I got a certified letter in from them about the fence june 2021, let me see if any others

On Fri, Apr 1, 2022 at 2:29 PM Sarah Zeeman <szeeman@gmail.com<mailto:szeeman@gmail.com>> wrote:
did not hear from them again about just the fence part until August 2021

On Fri, Apr 1, 2022 at 2:24 PM Sarah Zeeman <szeeman@gmail.com<mailto:szeeman@gmail.com>> wrote:
additional Fence -convos in march 2021 - I couldn't remember exactly but this clears it up some -  I went ahead and did apply during this time frame but didn't submit all the items yet for the permit as it wasn't fully decided on the vendor/design but wanted to get the process started moving with COB.

After this email, exchange I did not hear from them until August 2021

On Fri, Apr 1, 2022 at 1:45 PM Sally L. Monico <SCook@mmatllaw.com<mailto:SCook@mmatllaw.com>> wrote:
Got it, I will run with this draft and circulate a final copy shortly.


Sally Monico
11625 Rainwater Drive | Ste. 125 | Alpharetta, Georgia 30009
Direct:  404.365.4506
Main: 404.266.9171
smonico@mmatllaw.com<mailto:smonico@mmatllaw.com> *PLEASE NOTE MY NEW EMAIL ADDRESS

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